The Tax Lawyer Blog: Topical thinking from the lawyers at Moskowitz, LLP

FATCA withholding delayed for six months

Posted on July 12, 2013February 19, 2019 by Moskowitz LLP International Taxation,

On July 12, the U.S. Treasury Department and the Internal Revenue Service (IRS) announced that the implementation of the Foreign Account Tax Compliance Act (FATCA) would be postponed for six months to allow foreign entities to finalize their intergovernmental agreements with the IRS. As such, FATCA withholding by foreign institutions...

U.S. Government to Use the Treasury Department to Identify Individuals Owning Foreign Assets

Posted on June 18, 2013April 1, 2022 by Moskowitz LLP International Taxation, Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

At the G8 meeting in Ireland, the White House announced it's intent to facilitate international tax and business arrangement transparency by promising a plan to assist law enforcement and tax authorities in identifying those who own and control entities outside of the United States. We have been reporting on the...

Residency Under U.S. Tax Law

Posted on June 2, 2013February 19, 2019 by Moskowitz LLP International Taxation, Tax Planning & Compliance,

Taxation of non-U.S. citizens is determined based on the residency status of the individual or entity. Different from U.S. immigration laws, the tax laws divide taxpayer into two categories: Resident aliens are taxed in the same manner as U.S. citizens on their worldwide income, and Nonresident aliens are taxed according...

IRS to target “quiet” offshore tax disclosures in light of new report

Posted on May 1, 2013February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection, International Taxation,

Given the aggressive public overtures that Internal Revenue Service (IRS) officials have made regarding offshore bank accounts and tax evasion in the last five years, many taxpayers took advantage of the Offshore Voluntary Disclosure Program offered by the Internal Revenue Service. However, a report issued by the GAO (Government Accounting...

Offshore Bank Account Depositor Information Leaked

Posted on April 9, 2013February 19, 2019 by Moskowitz LLP International Taxation,

With thanks to Elizabeth Prehn, Law Clerk In early April 2013, the International Consortium of Investigative Journalists released their report, Secrecy for Sale: Inside the Global Offshore Money Maze. A New York Times Article on this report, states that "the leak of records mainly from the British Virgin Islands, the...

IRS Continues Offshore Bank Account Crackdown in 2013

Posted on January 10, 2013February 19, 2019 by Moskowitz LLP Tax: Audits, Litigation & Collection, International Taxation,

The IRS has started 2013 with a win by obtaining a guilty plea from Wegelin for conspiring with U.S. taxpayers and others to hide more than $1.2 billion in secret Swiss bank accounts. Further, the monetary fines imposed total more than $74 million. No banking institution is too great to...

DISTRICT COURT DECIDES FBAR PENALTY ASSESSMENT CASE – BOTH A WIN FOR THE GOVERNMENT & FOR OVDP PARTICIPANTS

Posted on November 21, 2012February 19, 2019 by Moskowitz LLP International Taxation,

Here at Moskowitz LLP, A Tax Law Firm based in San Francisco, CA, we have been following just how the Internal Revenue Service will collect FBAR penalties once imposed outside the scope of any Offshore Amnesty Program. In its decision November 8, 2012, the District Court for the District of...

South Korean government cracks down on offshore accounts

Posted on October 30, 2012February 19, 2019 by Moskowitz LLP International Taxation,

In the last 10 years, South Korea has seen an incredible surge in economic expansion. The country now represents the fourth largest economy in Asia, and the capital city of Seoul - particularly its Gangnam neighborhood - has become a capitalist paradise teeming with big-name brands and luxury boutiques. However,...

Offshore Amnesty Penalties: An Unfortunate Driving Force for Renouncing Citizenship

Posted on September 24, 2012February 19, 2019 by Moskowitz LLP International Taxation,

Moskowitz LLP, A Tax Law Firm, regularly counsels individuals with foreign connections on U.S. taxation issues, facing offshore amnesty penalties. Here in San Francisco and the Silicon Valley, in particular, and California in general, we have recently seen an increase in individuals considering renouncing their U.S. citizenship1 and green cards...

Just how is the Expatriation Tax Calculated?

Posted on September 11, 2012April 1, 2022 by Moskowitz LLP International Taxation,

Introduction It has been all over the news lately, wealthy U.S. taxpayers, such as, Eduardo Saverin (a Facebook founder), Denise Rich (songwriter), and another eighteen hundred, or so, have forfeited their U.S. citizenship for U.S. tax reasons. Federal law provides that some U.S. taxpayers who elect to renounce their U.S....

U.S. Tax Effects of Treaties in the Context of Foreign Investment in the U.S.

Posted on September 6, 2012February 19, 2019 by Moskowitz LLP International Taxation, Real Estate Law,

Introduction Foreign investors in the U.S. tend to have the same goals as their U.S. counterparts. Like U.S. taxpayers, foreign investors seek to minimize their income tax liabilities associated with their U.S. real estate and business investments. However, foreign investor’s objectives are clouded by the fact that they are not...

Piercing Asia – U.S. Offshore Bank Account Crackdown results in data on undeclared bank accounts with Hong Kong Connections

Posted on August 24, 2012February 19, 2019 by Moskowitz LLP International Taxation,

On August 20, 2012, the United States Attorneys Office issued a press release regarding their most recent Offshore Bank Account Plea Agreement reached. The taxpayer, Jacquez Wajsfelner pled guilty to willfully failing to file foreign bank account reports (FBAR) for several Swiss Bank Accounts. Slightly outside the average age of...

Non-Citizens Risk Immigration Status for Offshore Bank Accounts

Posted on August 22, 2012February 19, 2019 by Moskowitz LLP International Taxation,

The increased focus by the IRS on foreign income has generated a lot of news and a slew of criminal prosecutions. While US citizens need to consider the possibility of monetary penalties or a long prison sentence, resident non-citizens (green card holders) also need to worry about the possibility of...

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